Read our 2027 thematic examination programme
We are continuing our programme of thematic examinations as part of our ongoing supervision of businesses. These examinations respond to current or emerging regulatory and financial crime risks. They involve firms from different sectors to assess compliance standards and understand associated risks. Our next two themes will focus on compliance with financial crime obligations:
- customer risk assessments
- beneficial ownership and control, with a focus on understanding complex structures and identifying control by other means
For each theme, we will issue a questionnaire to selected firms. The questionnaire will cover relevant obligations set out in the Money Laundering (Jersey) Order 2008 and the AML/CFT/CPF Handbook. After analysing responses, we will select a sample of firms for onsite examinations. Supervisors will contact firms directly once responses have been reviewed. Onsite examinations will take place in the first half of 2027 for customer risk assessments and the second half of 2027 for beneficial ownership and control.
Customer risk assessments
To prepare for the onsite examinations in the first half of 2027, we will soon issue a thematic questionnaire. If your firm is selected, you will receive an email with instructions and a deadline for submission. The questionnaire will be sent by email on or before 9 October 2026 and will also be published on our website.
The questionnaire will cover key areas for the customer risk assessment thematic examination. By publishing the questions, we encourage all firms to use them as a self-assessment tool, even if not selected for the examination.
The questionnaire will cover the key areas of focus for the customer risk assessment thematic examination set out below. By publishing the questions in full, we encourage all firms to use it as a self-assessment tool, regardless of whether they are included in the thematic examination.
Rationale for this theme
Customer risk assessments are a key part of an effective AML/CFT/CPF control environment. They help with decisions about customer acceptance, ensure the right level of due diligence, and support ongoing monitoring. By examining firms’ systems and methods for assessing customer risk, we aim to identify trends, highlight good practice, and share observations to help firms strengthen their approach.
In 2021, we published a feedback paper on customer risk assessments. Firms may find it useful to review this paper, as the observations and examples of good practice remain relevant.
Your obligations
Firms must:
- carry out identification measures and assess the risk of money laundering, terrorist financing, or proliferation financing in business relationships or one-off transactions
- maintain policies, procedures, systems, and controls to support the assessment and management of customer risk
- ensure appropriate governance and oversight
We expect your systems and controls to cover:
- obtaining enough information to assess customer risk
- maintaining an effective methodology that reflects associated risks
- applying proportionate due diligence based on customer risk
- re-assessing customer risk during periodic reviews or trigger events
- documenting the rationale and approval for changes to risk assessments
- monitoring the effectiveness of controls and keeping information up to date
Key areas of focus for the examination
We will focus on:
- governance and oversight of customer risk
- systems and controls supporting risk assessment and management
- customer risk assessment methodologies
- adequacy and accuracy of information obtained
- ongoing monitoring of customer risk
- testing and reporting on the effectiveness of risk assessment methods and compliance
Beneficial ownership and control
Rationale for the theme
Transparency of beneficial ownership is central to our AML/CFT/CPF framework and our commitment to combatting financial crime. The 2024 MONEYVAL Mutual Evaluation Report highlighted areas for further supervisory focus, including complex structures and identifying individuals who control through other means.
We last examined beneficial ownership and control in 2022, focusing on customers with trust structures in the ownership chain.
Key areas of focus for the examination
The 2027 thematic will focus on:
- how firms understand beneficial ownership and control of complex structures, based on revised guidance published in the AML/CFT/CPF Handbook on 31 May 2026
- how firms assess and document control held through other means when applying the three-tier test
This update gives advance notice of the thematic examination on beneficial ownership and control. We will provide further details on timing, scope, focus areas, and approach in due course.
Next Steps
If you receive an email with a link to the customer risk assessment questionnaire, please follow the instructions and submit your response before the deadline.
After all responses are received, we will analyse the data and select firms for onsite examinations starting in the first half of 2027. If your firm is selected, your supervisor will notify you in December 2026. Information requests for this thematic will not be issued before January 2027.
If you respond to the questionnaire but are not selected for an onsite examination, we may follow up on a sample of your responses to verify accuracy.
We expect you to deal with us openly and cooperatively, and to be candid in your responses.
Our feedback paper will be published after the onsite examinations and will include aggregated questionnaire data. We welcome your feedback on the information and the publication.
Contact us
If you have any questions about the thematic examination programme, please contact the Examination Unit at fscseu@jerseyfsc.org.